Policy & Practice | Spring 2025
socioeconomic outcomes. The cor relation between untreated mental health and substance use disorders and involvement in the criminal justice system is well documented. 7 Treatment and support services during the reentry process help individuals address the root causes of their involvement with the justice system. Housing support, case management, and peer-support programs can help individuals find stable housing, secure employment, and engage in community activi ties. By involving behavioral health agencies, housing providers, and social services organizations in the reentry process, the waivers ensure there is a coordinated approach to helping these individuals thrive in their communities. Implementation Challenges and Considerations While the potential benefits of 1115 reentry waivers are clear, implementing these programs comes with significant challenges. Public Consulting Group (PCG) has supported California, the first state in the nation to implement a reentry waiver, to develop and test pre-release services. States that have implemented reentry waivers early can provide valuable insights into the com plexities of scaling such initiatives. People Challenges n States, carceral facilities, and justice system partners need new skills, knowledge, and staffing capacity, as jail and prison health care are being treated as part of the larger health care ecosystem for the first time through these initiatives. n There are needs for new relation ships between entities such as Health-Related Social Needs pro viders, managed care plans (MCPs), and carceral facilities. n There are challenges with change management, including willingness and readiness to change. Opportunities n Work with stakeholders to develop avenues for feedback, proactive engagement, and collaboration on an ongoing basis to ensure issues are identified early and solutions are informed by practitioners.
n Provide technical assistance and funding support to stakeholders as they work through the implementa tion process, build capacity, and address new staffing needs. Process Challenges n Prison health providers do not have the infrastructure or business pro cesses to bill Medicaid and facilitate wraparound service delivery. n Implementation timelines can be a challenge for carceral facilities. The rapid changes necessary to meet reentry waiver requirements can be difficult for agencies starting at dif ferent readiness levels. Opportunities n Design reentry programs with an iterative approach, starting with a few pilot agencies to identify and address process pain points. Build in reflection and review points to ensure modifications and adapta tions are made proactively. n Encourage phased implementation, ensuring agencies gain familiarity with foundational Medicaid pro cesses and establish appropriate workflows before launching services. n Develop practitioner-focused imple mentation tools that break down requirements, key decisions, and process needs at various phases of service roll-out. n Complex technology systems that require identification, implementa tion, and training are necessary for the carceral facilities to participate in screening, service delivery, and referral processes. n There is a need for bi-directional data exchange, data sharing, and billing and referral systems between carceral Opportunities n Support justice system partners in identifying standard data col lection, reporting, and program evaluation needs, and the tech nology required to support the new services being implemented. Technology Challenges facilities, justice system partners, MCPs, and Medicaid agencies.
n Provide funding to support devel opment, enhancement of data exchanges, or both. n Set up learning collaboratives specifi cally focused on technology, sharing solutions to build strong partnerships between health care providers, justice system partners, carceral facilities, and community organizations. Looking Ahead As more states implement 1115 reentry waivers, the potential for these programs to improve the lives of indi viduals involved in the justice system grows. With a focus on continuity of care and promoting community rein tegration, reentry waivers represent a transformative opportunity to address health care disparities and support individuals during one of the most challenging transitions of their lives. For states looking to implement these waivers, success will depend on thoughtful planning, collabora tive partnerships, and an unwavering commitment to improving the health and well-being of these community members. With the right support and resources, reentry waivers can help build a more effective and just health care system for all. Reference Notes 1. https://bjs.ojp.gov/library/publications/ prisoners-2022-statistical-tables 2, 3. https://www.medicaid.gov/federal-policy guidance/downloads/smd23003.pdf 4, 5. https://aspe.hhs.gov/sites/ default/files/documents/ d48e8a9fdd499029542f0a30aa78bfd1/ health-care-reentry-transitions.pdf 6. https://www.vera.org/publications/ overdose-deaths-and-jail-incarceration/ national-trends-and-racial-disparities 7. https://www.sciencedirect.com/science/ article/pii/S074054721400083X
Julia Kessler is a Senior Consultant at Public Consulting Group.
Christine Newhall is an Associate Manager at Public Consulting Group.
Katie Thomas is a Senior Consultant at Public Consulting Group.
Shannon Weaver is a Senior Consultant at Public Consulting Group.
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Spring 2025 Policy & Practice
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